Welcome….

This is the first post on this blog.

Minnesota is rich in blogs, and rich in alternative media such as The Uptake and Daily Planet.  Is another blog really needed?  Good question!   My main reason for setting it up is to have a place to archive and link to various emails and posts I’ve sent about Minnesota environmental issues. Continue Reading →

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A detailed review of every contaminated site in Minnesota is urgently needed….

One of the best elected officials I know of is Cam Gordon of the Minneapolis MN City Council.  Gordon is a Green Party member, one of a relative handful of official Greens holding office in the United States.  I don’t agree with all Gordon’s positions, of course, but he shows an impressive ability to maintain independent and thoughtful positions while seeming to maintain working relationships with his colleagues. In March, 2014, Gordon posted this commentary (below) on one of the more consequential environmental scandals to surface recently in Minnesota. Continue Reading →

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Public comment time on MN air monitoring plan

“Air Monitoring” touches on many localities and many issues.   Whether the concern is high asthma rates in North Minneapolis due to dirty air, or disease-causing silica dust from “frac” sand mining, or “regional haze” limiting views in the Boundary Waters Canoe Area, or coal and “biomass” burner emissions sickening and killing millions of people worldwide, or toxic fumes in a basement because a contaminated site was never really cleaned up, measuring the actual composition of our air is a key step in the chain of events that need to happen to improve it.

Monitoring in a broad sense can be aimed at measuring the overall state of the air (“ambient” monitoring), the impacts of a particular facility (“fenceline” monitoring), what is coming out of a particular smokestack (“continuous emission monitoring” or “performance testing”), the air quality in your home or workplace (radon testing, for example), or wearing a personal air monitor for a day to determine individual exposure.   It might be a “bucket brigade” monitoring program organized by a community organization.  It might be other things.

People tend to assume that if they are concerned about bad air, monitoring will confirm the problem.  This may or may not prove to be the case.  Often it does not, because “the devil is in the details” and the details of air monitoring are very complex and not easy to understand.

Based on incomplete information provided by the Pollution Control Agency (MPCA), it appears that about 64 cents per person per year is being spent on air monitoring in Minnesota.  (Half or more of the money is federal in the form of grants from EPA,)  Are we getting what we need from that expenditure?

The MPCA has estimated that human-caused (“Anthropogenic”) PM-2.5 (fine particle) air pollution is killing 3800 Minnesotans per year, sending 940 to the hospital, sending 770 to emergency rooms, causing 260,000 lost work days, causing 1600 non-fatal heart attacks, and so on.   The same report estimates that ozone pollution is killing another 61 Minnesotans per year, sending 440 to the hospital, causing 140,000 missed school days, and so on.  The MPCA estimates the cost of all this death and disease at about $35 billion.  Of course, there are many other types of air pollution also causing harm, and the estimates must be considered very approximate.  (The MPCA seems to value a human life lost at about $900,000.  How much do you think yours is worth?)  In any case, these numbers suggest that the annual cost per living Minnesotan is about $6290 per year, about ten thousand times the amount being spent on monitoring the quality of our air.

Most air monitoring in Minnesota is done by, or with the advice of, the Minnesota Pollution Control Agency (MPCA), and is a fairly narrow subset of the whole world of monitoring.  As required by the US Environmental Protection Agency, a 30 day public comment period was held during June.  At the request of people, the comment period was extended to Aug 1, 2014.  But, the PCA says it will accept comments at any time.

See Action Alert: Ask for public comment extension on Minnesota air monitoring plan.  In this I tried to point out some of the concerns and issues around monitoring.

In response to Data Practices act requests, the MPCA provided information on grants and budgets.  Some examples:

“Near Roadway NO2 Monitoring Site Establishment Grant” (USEPA, $200,000)
“Particulate Matter (PM 2.5) Air Monitoring Network Cooperative Agreement” (USEPA, $1,324,694)

This is from an alert I received this morning [Let me know if you want the whole thing in order to act on it.]

” … Tell the Winona Mayor and City Council members to require air monitoring at all frack sand mines, processing, and transportation facilities in the city of Winona. They may consider the monitoring at their meeting 6:30 pm on Monday, August 4.”

“I believe that without monitors at the fence lines of each facility, residents and visitors have no idea whether they are at risk from the crystalline silica dust these facilities produce.”

The [Citizens Environmental Quality Committee (CEQC)] has 3 times made their recommendations to the City’s Planning Commission.  Each time they have been rejected as unnecessary and too costly for the operators of these facilities.  The CEQC now wants the Mayor and City Council to consider their recommendations directly.

Many people in North Minneapolis have expressed concern about the movement or shutdown of an air monitor.

Many people were concerned when they found out there was NO ozone monitor in Minneapolis or St. Paul.

People are concerned that pollutant “spikes” as reflected in real-time data but are not recorded.

Some thoughts from Muller:

Minnesota needs to take a broad look at air monitoring to ensure that real needs are being met and that adequate funding is available.

These real needs include, for example, helping people who are being sickened or stunk out of their homes by neighbors’ wood stoves or backyard boilers.  This might involve personal exposure monitoring.   The MPCA and MDH should be prepared to respond in a substantial and meaningful way.

The MPCA and the Minnesota Department of Health need to be more proactive in regard to air monitoring in Environmental Justice communities.  Consultation with EJ communities is needed to work out the details.

Monitoring is not being recorded in small enough time intervals to detect “spikes” of pollutants that may cause health effects.  Even one-hour intervals are probably not small enough.  Not enough monitoring data is available in real time on the Internet.

There are two non-routine air monitoring projects related to North Minneapolis, the “Community” project and the “ North Minneapolis” project instigated by the Northern Metals permitting controversy.  These may be very distinct internally to the MPCA but are likely to be less so to community members.  The results of these two efforts should be integrated to the extent possible.

The “detailed results” of the “North Minneapolis” project contain more detail on wind directions & etc.  It would be desirable to present this information in the same level of detail for the “Community” project.

In general, air monitoring tends to focus on compliance, and to a lesser extent research and enforcement.  More direct emphasis on health protection is needed.

A major concern is the focus on presenting 24 hour data as if the point was to establish, or imply, compliance with the 24-hour PM-2.5 standard of 35 micrograms per cubic meter.  It is repeatedly stated that the 24 hour averages of measured concentrations are below the National Ambient Air Quality Standards (NAAQS).  This seems intended to imply that air quality problems aren’t present, at least for PM-2.5

Looking at the raw (but QCd) data for the North Minneapolis (31st Ave N. & N. Pacific Street) monitor from Jan 1, 2013 to March 31, 2014, it appears that there were 115 hourly intervals during which PM-2.5 concentrations were above 35.  For 31 hours they were above 50.  For five hours they were above 70.  The peak value was 126, at 6:00 PM on May 14, 2013.  For 370 hour intervals no results were recorded because the equipment was not working properly.

It is well-demonstrated in the literature that air pollutant levels below the National Ambient Air Quality Standards produce health effects.  There may be a “Linear No Threshold” relationship.  It is well known that the setting of air quality standards are influenced by political considerations (influence of big polluters, Chamber of Commerce ….) and the setting of standards lags behind what the scientific literature has to say, sometimes by many years.   Health data–asthma, etc–for neighborhoods in Minneapolis strongly suggest that air quality is impacting human health.  The PCA itself, in a presentation to a legislative committee, has estimated widespread health effects as noted above.

Minnesota is hone of the highest radon level states because uranium is widely distributed in the states complex geology.  The EPA “action level” of 4 picucuries per liter corresponds to an estimated lung cancer death rate of one in seven thousand, a much higher risk level than typically considered acceptable.  (The World Health Organization recommended level is 2.7.)  An EPA presentation estimated that 564 Minnesotan’s per year die of radon-related lung cancer.  Radon deaths can be prevented, or greatly reduced, by testing homes for radon and installing “mitigation” systems to suck out the radioactive gas.  The cost per life saved has been estimated at $190,000.  The cost of treating a case of lung cancer has been estimated at one million dollars.  As noted above, the MPCA estimated the value of a human life lost to air pollution as about $900,000.  These facts make clear that it would be highly cost-effective for Minnesota to ensure that every home in the state is tested for radon and mitigated if radon levels above 2.7 are found.

(Radon is the “turf” of the Minnesota Department of Health and not the Pollution Control Agency, and is outside the formal scope of the “network plan” the PCA seeks comment on–although, at the federal level, radon seems to be the turf of the EPA.)

A quick review of the “2012 Criteria Point Emissions Ranking Report” indicates that many of the grossest belchers are part of or connected to mining.  (Including Minnesota Power as the primary supplier of electric power to mining facilities.)  For example 7 of the top 10 NOx emitters, 8 of the top 10 Particulate Matter emitters, 5 of the top 10 sulfur dioxide emitters, and 3 of the top 10 lead emitters are mining-connected.  This strongly suggests that instead of an ongoing “free ride,” mining and mining-related facilities should be targeted for monitoring and permit tightening.

Minnesota needs to be more pro-active in setting state-level standards below national standards when “the science” and local needs support doing so.

Conclusion:

The monitoring plan on which the MPCA has sought comments is very complex, but in reality describes only a part of the air quality monitoring Minnesota really needs as part of a serious effort to improve air quality and public health.

Tell the MPCA what YOU think:  rick.strassman@state.mn.us .

Alan Muller

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Action Alert: Ask for public comment extension on Minnesota air monitoring plan

“Air monitoring” is really “air pollutant monitoring” and means measuring known-to-be-harmful substances in the air we breathe.  This sounds simple but is not.  Often enough we are not measuring what we really should be measuring, or are not given correct interpretations of the results.

In Minnesota, most air monitoring is done by the Minnesota Pollution Control Agency (MPCA).  The primary motivation of the MPCA is to show that air quality is OK.  The conflict of interest is obvious in that the MPCA issues the “permits to pollute” and is not motivated to admit that the resulting emissions cause problems.  That said, there is more monitoring of air pollutants in Minnesota than some other places and some monitoring goes beyond federal (Clean Air Act) requirements.  [Note:  I'm talking about the collective motivation of the MPCA under the political direction it gets.  This does not speak to the personal motivations of the staff, many of whom do care about "pollution control."]

Monitoring is technically complicated and often the data can be interpreted in different ways.  For example, the MPCA may say that the “24 hour average” concentration of a pollutant is below the National Ambient Air Quality Standard.  This may be intended to give the impression that air quality is OK and people should stop worrying and complaining.  But within that 24 hour average could be “spikes” of intense pollution that are, in fact, making people sick.

In general, it is assumed that the air is OK to breathe unless measurements prove otherwise, even if you are under a giant industrial smokestack.  So, air polluters like less monitoring.  Some people could suspect the MPCA of putting monitors where the pollution ISN’T, and avoiding putting them where the pollution IS.  For example, some were surprised to learn that there were no ozone monitors in Minneapolis or St. Paul.  There are no monitors in Benson, MN, although the MPCA has issued permits there for an ethanol plant and a turkey litter incinerator, in spite of the fact that exceedances of air quality standards were predicted.  There are no monitors in Perham, where an unpermitted facility was predicted to cause exceedances of air quality standards, and where the MPCA has promoted, permitted, and partially paid for an expanded garbage incinerator.  Is anyone really protecting the health of people in Benson or Perham?

Evidence is piling up of health damage from air pollutants at far below the legal “standards.”  (It is very hard to lower standards because industrial and electric utility interests lobby against it, and these have far more money than health/environmental interests.)  For example, on March, 2014 the Guardian reported:

“Air pollution has become the world’s single biggest environmental health risk, linked to around 7 million � or nearly one in eight deaths in 2012 � according to the World Health Organisation (WHO).

The new figures are more than double previous estimates and suggest that outdoor pollution from traffic fumes and coal-burning, and indoor pollution from wood and coal stoves, kills more people than smoking, road deaths and diabetes combined.”

From a post last AprilAn MPCA report, based on EPA methodology used to estimate the cost-effectiveness of air regulatory programs, estimates that all man-made PM2.5 pollution is killing 3,800 people per year in Minnesota, those lost people being worth 34 billion dollars.  The Minnesota PM2.5 emissions alone are estimated to be killing 1,600 people per year, those lost people being worth $14 billion dollars.  Of course, many more people are made sick but survive.  For example, Minnesota PM 2.5 emissions alone are estimated to be causing 460 non fatal heart attacks per year, worth forty nine million dollars per year.” (Thanks to Rep. Jean Wagenius for asking for this report.)

The MPCA, along with industrial polluters, is funding a campaign to prevent the US EPA from finding Minnesota in “non-attainment” of the ozone air quality standard.  This, perhaps with intentional humor, is called the “Clean Air Dialog” or “Clean Air Minnesota,” and is run by an industrial front–“astroturf”–group calling itself “Environmental Initiative.”  The funders of this scheme are listed as 3M Company, Flint Hills Resources (the big Koch Brothers oil refinery) and the MPCA.  See the Role of Shame of participants.  Of course, “non-attainment” would be the best thing for air quality in Minnesota because it would force some serious planning and regulating for cleaner air.  For our purposes here we need to wonder whether an agency seeking to evade “non-attainment” can really be trusted to monitor ozone levels. [Note:  The current version of the "Clean Air Minnesota" scam is less blatant about the objective of evading non-attainment, but the real objectives haven't changed.]

Every year the MPCA is required by the US Environmental Protection Agency to open a 30-day public comment period on an “Annual Air Monitoring Network Plan for Minnesota” for the upcoming year.  Few people comment on this; few people know about it.  It is not easy to understand what it really says.  (One regular commentor is Cliffs Natural Resources, operators of a taconite plant in Silver Bay, North of Duluth.  They don’t want monitoring for asbestos in the air)

But, interest in air monitoring is growing.  People in North Minneapolis want to know if their air is making them sick.  People want to how much frac sand dust is in their air, or could be.  People are tired of breathing wood smoke pollutants, “biomass” burner pollutants, coal plant pollutants, feedlot pollutants, traffic pollutants ….

It is reasonable to ask whether the proposed “monitoring plan” responds adequately to these concerns.  The 44 page draft plan was published on June 2nd with a public comment period extending to July 1.  We immediately responded with a Data Practices Act request for more information:

The PCA has just issued a public notice of opportunities to comment on the draft 2115 state Air Monitoring Plan.  I expect to do this as I have done in the past.

The plan document contains considerable technical information but little if anything about the budget for air quality monitoring.   However, it has been otherwise stated that funding limitations have had impacts on air monitoring in Minnesota.

Therefore, pursuant to the MN Data Practices Act, I request a summary of the funds allocated to air quality monitoring in Minnesota from 2004 to 2014, including total amounts and sources (state/federal, etc).  I also request all documents that speak to the adequacy, or otherwise, of this funding, and impacts of funding limitations on the extent of monitoring statewide.

This request also includes all grant applications, and/or grants received, for air monitoring and related activities.

This request also includes all requests for air quality monitoring in Minnesota received by the MPCA between 2004 and 2014, and the disposition of those requests.

This request also includes all correspondence between the MPCA and the Minnesota Department of Health, the Department of Public Safety, or other Minnesota entities, on or related to the subject of air quality monitoring.

This request also includes all correspondence between authorities in Wisconsin, Iowa, South Dakota, North Dakota, Manitoba, Ontario, the Canadian federal government, and the USEPA, and other US federal agencies, and regional/cooperative bodies including the International Joint Commission, regarding air quality monitoring in Minnesota, during the past five years.

This request also includes any presentations to or correspondence with the Legislature regarding air quality monitoring during the last five years, including budget requests.

My intent is to use this information to develop responsive comments are requested by the MPCA.  Given that:

“Public Comment Period Begins: June 2, 2014″
“Public Comment Period Ends: July 1, 2014″

Time is of the essence in receiving the requested materials.  Please contact me if any clarifications are called for.

Some but not all of this information has been provided.  The info on funding has not arrived.

At least four pages of the report make reference to monitoring being shut down or not started up due to funding limitations.

I sounded out the MPCA on extending the public comment period and was basically told “not if just you are asking for it.”

So, here’s the action part of this Action Alert:  Ask the MPCA to extend, or reopen, the public comment period on the air monitoring plan for at least 30 days, and provide all requested information (we will post it all):

Contact:

John Linc Stine, Commissioner, MPCA: John.Stine@state.mn.us , 651-757-2014
Susan Hedman, Regional Administrator, EPA Region 5 (Chicago): hedman.susan@epa.gov , 312.886.3000
Rick Strassman, MPCA:  Rick.Strassman@state.mn.us , 651.757.2760
your Minnesota Senator and Representative: Who Represents Me?

Alan Muller

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Strange nonsense at the Minnesota Environmental Quality Board (and the MPCA)

Minnesota’s Environmental Quality Board (EQB), and it’s Climate Change Subcommittee, held a meeting on June 18, 2014.

“The mission of the Environmental Quality Board is to lead Minnesota environmental policy by responding to key issues, providing appropriate review and coordination, serving as a public forum and developing long-range strategies to enhance Minnesota’s environmental quality. The Environmental Quality Board consists of a Governor’s representative (by law the board chair), nine state agency heads and five citizen members. Minnesota Statutes, Chapters 103A, 103B, 116C, 116D and 116G (Statutes and Rules of the EQB)”
Continue Reading →

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The unending PolyMess ….

For about seven years various state and federal agencies have been doing “environmental review” of this project, the first of its kind to be proposed in Minnesota.   Mining industry people and their agents, including numerous Minnesota politicians of various parties, claim the proposed copper-nickel (sulfide) mining is the economic salvation of Northern Minnesota. The enviro side predicts disastrous pollution will result. Who is right?  Or does the truth lie somewhere in between? Officially the NorthMet Mining Project, the supposed plan is to dig up and process 240 million tons of this over a period of twenty years:

“The NorthMet Deposit is one of 10 known significant mineral deposits that have been identified within the 30-mile length of the Duluth Complex and just south of the eastern end of the Mesabi Iron Range. The complex is a well-known geological formation containing large quantities of copper, nickel, cobalt, platinum, palladium, and gold. The MDNR has estimated that the entire complex contains as many as 4.4 billion tons of mineral resources grading at 0.66 percent copper and 0.20 percent nickel. The NorthMet Deposit is believed to be the second largest deposit within the Duluth Complex and represents nearly 25 percent of the known mineral resources in the area.”

The Minnesota Department of Natural Resources (DNR), the US. Forest Service, and the US Army Corp of Engineers (the “lead agencies”) have produced the most recent environmental review report, a 2165 page “Supplemental Draft Environmental Impact Statement (SDEIS).”  In addition, the agencies have produce videos and “Fact Sheets” with generally cheerleading tones but factual errors.

The US Environmental Protection Agency had called a previous Environmental Impact Statement  “inadequate,” saying in a Feb 18, 2010 letter that the project may “may have substantial and unacceptable adverse impacts on aquatic resources of national importance.” In the runup to three recent public meetings, DNR Commissioner Tom Landwehr has done a frenzied road show, basically telling Minnesotans to see things through the same rose-tinted lens used by the DNR to evaluate mining projects.

The Duluth New Tribune lost its collective mind in one of the most insulting editorials I’ve ever seen in a mainstream newspaper.  Making copper mining happen seems central to the political agenda of Governor Mark Dayton.  Dayton has gone so far as to say he’d like to see the US Environmental Protection Agency abolished.  See Carol Overland’s Legalectric post on this. This is an issue on which many Minnesota NGO’s have been able to focus effectively.

Good information is available on the sites of Audubon, WaterLegacyMining Truth, and many others. Many people have studied the SDEIS in more detail than I have, and have identified many deficiencies.  I’ll just add a few thoughts.

The public hearings on this are inadequate and orchestrated.  Look at this about the last–presently scheduled–hearing in St. Paul on Jan 28th “Because of limited time, moderators will pick 60-80 names at random to deliver oral comments of up to 3 minutes in the large auditorium between 6:45 and 10:00 PM.”   This is a shameless attempt to limit public testimony.  Instead, the hearing should be continued on as many evenings as necessary until everyone has had a chance to talk.  In the previous cycle of public comments in 2009, the DNR got attention for refusing to let people testify in public at all.  I wrote this up at the time:”PolyMet, manipulation, and public meetings/hearings.”

According to the Minneapolis Star-Tribune, about 640 people signed up to speak on the 28th but only 59 were allowed to. State regulatory agencies like the DNR and MPCA can’t deal effectively with politically connected industries like mining in Minnesota.  (Or garbage-burning in Minnesota, or agriculture in Minnesota, or ….).  This is why the supervision of federal agencies is so important–they can be more insulated from state-level politics and help maintain the integrity of the process.  So how this current cycle of environmental review will depend a lot on whether the federal agencies, especially the EPA, again do their jobs, or whether they roll. In 2010 EPA called out “substantial and unacceptable adverse impacts on aquatic resources.”  Has anything changed to alter that conclusion?  I doubt it, because (1) the essential characteristics of the project haven’t changed, and (2) the “modeling” of water pollution impacts seems to be based on incorrect baseline data on how much water will flow through the site.   This casts doubt on the validity of all the predictions of how pollutants in nearby surface waters would change.  A good writeup of this here:  “Study may need major fix.”

The Native American tribes/bands/organizations  involved in the effort have identified 18 official “Major Differences of Opinion.”  They of course, “were here first,” and remain more closely connected to the lands and waters of the area.  They apparently have been pointing out the problems with the water flow baseline for some time.  Many of their “differences of opinion” seem like no-brainers.  Number 17 says:

“Fond du Lac and Grand Portage do not agree with statements in the document that indicate there is “no impact” when that assertion is based on not exceeding an evaluation criteria. They believe the SDEIS should acknowledge where there is a change, regardless if a criteria or standard is exceeded. With regard to the water quality effects analysis, Grand Portage and GLIFWC note that evaluation criteria are not equivalent to water quality standards. Grand Portage further notes that some evaluation criteria are high enough to cause human health impacts and evaluation criteria are not equal to or a substitute for water quality standards compliance. GLIFWC notes that in some areas, for example the cumulative effects section for the Partridge River, the text states all water evaluation criteria would be met, though water quality standards would be exceeded for several constituents.”

In other words, the “lead agencies” are simply cooking the books on water pollution.

Why, after about seven years of environmental review work, is the news so bad.  Simply because the news IS what it is.  There is no way such an operation, as the mining industry would run it, can avoid causing major problems.  The key reason:  the ore and some of the overburden contain sulfur.  When this is broken up, and exposed to atmospheric oxygen and moisture, sulfuric acid (H2SO4) is formed.  This dissolves other harmful constituents from the rock and directly adds sulfates (SO4) to the water.  Billions of tons of material are involved, so the “reactive” rock would cause mischief for hundreds or thousands of years.

So why are Governor Dayton, many members of the Minnesota Legislature, and others, pushing so hard for this?  Officially, “jobs.”  According to the SDEIS, Polymet claims the jobs created would be: Construction:  500 direct jobs plus 332 indirect jobs.  Total 832 Operation: 360 direct jobs plus 631 indirect jobs.    Total 991 Yet, these apparently are Polymet’s numbers and most likely exaggerated.  And they don’t mention the jobs that might be lost in other industries such as recreation and tourism.

The Current Population Survey of households showed 2,834,248 employed persons in Minnesota for December, 2013.  Minnesota added 9,500 jobs in December 2013 according to the CPS employment measure or 5,901 by the Current Employment Survey (The two surveys use different methods). To simplify, lets assume there are three million jobs in Minnesota and PolyMet generates a net of 500 more.  Then PolyMet would provide 0.017 percent of the jobs in Minnesota.  About equal to the number Target is laying off at its corporate headquarters.  Granted these jobs are very important to the people who need them, and 500 jobs on the Range are likely harder to come by than 500 jobs in the Cities.  But how much sense does it make to bring in a facility with a very high probability of crapping up a sizeable chunk of Minnesota, and perhaps increasing pollution of Lake Superior, to increase employment in Minnesota by 0.017 percent?

How reliable are the pollution numbers and other numbers in the SDEIS? The documents say the “Life of Mine” would be 20 years and the plant would process 32000 tons per day of ore.  But what is to ensure that the operation would shut down after 20 years?  Nothing, in my opinion.  This is not any more likely than that Minnesota’s nuke plants would shut down at the end of their 25 year licenses.  No reactor in the US has ever been denied a license extension.    As long as there is copper-nickel or to be dug up profitably, activities are likely to continue.

A more reliable source that the SDEIS and its predecessors may be a report on Polymet by Edison Investment Research Limited.  Edison claims to be “Europe’s leading independent investment research company …” and has an office in Toronto. Edison says “PolyMet Mining Corp. is a research client of Edison Investment Research Limited.” I think this means PolyMet pays Edison to promote Polymet to investors. It seems likely that the information in this report is what PolyMet want to pitch to investors.  The report says:

“We look for management to create additional value through expanding capacity or consolidating the Duluth Complex. In addition, we believe PolyMet might be able to optimise NorthMet’s ore processing rate while staying within the permitted emissions level.”

Our base case valuation is US$479m or US$1.49/share undiluted or US$1.32/share diluted. Our DCF valuation uses a 10% discount rate, a 20-year mine life and long-term price assumptions of US$2.96/lb for copper and US$10.14/lb for nickel. We assume a US$450m capital cost with US$100m financed with equity at US$0.85/share and US$350m funded with debt. No value is ascribed to the unused resource.

Our upside valuation, based on an expansion to 90,000 t/d [emphasis added] at an additional capital cost of US$400m, is US$1,254m or US$3.89/share undiluted or US$3.08/share diluted. Sensitivities: Permitting is key The important issues facing PolyMet are: permitting, geology, commodity pricing, access to capital and project execution. PolyMet is a junior development mining company… (“A junior mining company has no mining operations and is essentially a venture capital company.”)

PolyMet acquired the Erie Plant from Cliffs Natural Resources in transactions in 2005 and 2006 for US$32m. This materially reduces the capital cost to build NorthMet and shortens the required construction time.

NorthMet will start with a volume of 32,000 t/d (short tons), but historically the plant operated at 100,000 t/d and we believe an operating rate of at least 90,000t/d should be attainable [emphasis added].

PolyMet will be an open-pit mine. Run of mine rock will be delivered to a loading system, loaded onto rail cars and delivered to the Erie Plant six miles to the west. PolyMet will mine approximately 32,000 tons of ore per day in Phase I. It will have a life of mine stripping ratio of 1.4 to 1.0, but will start out with a very low stripping ratio the first several years.  [This means that for every ton of ore dug out, 2.4 tons of material will have to be moved, including the ore and the overburden.]

Waste rock with the lowest sulphur content will be placed in a stockpile with a ground water containment system. The remaining waste rock will be temporarily placed on foundations, liners and containment systems, then backfilled into the pit for underwater storage. Ore will be transferred from rail cars into crushers formerly used to crush iron ore. Once the ore is crushed to 0.5 inches it will be further ground in rod and ball mills, reducing it to 120 microns. The finely ground ore will be sent to new flotation cells that will separate the metal-bearing rock concentrate from non-metal-bearing rock (tailings). The flotation circuit will produce separate copper and nickel concentrates. Tailings will be collected from the flotation cells and sent to the existing tailings basin. Five years of testing have shown these tailings will not generate acid. The metals are separated into concentrate to be sold for further processing. … 

Initial annual production of Phase I is estimated at 72m pounds of copper, 15m pounds of nickel and 106,000 ounces of precious metals. Based on the economic  summary in the 2013 updated 43-101 Technical Report, NorthMet will have a cash cost of US$1.05 per pound of copper based on co-product economics and a negative cost of US$0.28 per pound of Copper based on byproduct economics. [copper now sells for around $3.25/pound but prices are highly volatile.)

The Erie Plant provides PolyMet with a competitive advantage. The Erie Plant is a large grinding and milling facility with a tailings pond. The plant includes two rail dump pockets, two primary 60″ gyratory crushers, eight secondary 36″ gyratory crushers, seven tertiary standard cone crushers, 14 seven-foot short-head crushers, 30 mill circuits each comprising one 12′ x 14′ rod mill, one 12′ x 14′ ball mill, three 12′ x 24′ regrind mills and maintenance facilities. It also has conveyors, feeders, bins, auxiliary facilities and a 225MVA high-voltage electrical substation, with a water supply, road, tailings basins and rail facilities. It owns a 120-rail car fleet, locomotive fuelling and maintenance facilities, and water rights. The Erie Plant operated from 1957 to 2001, processing taconite, and was shut down in the bankruptcy of its owner, LTV Steel Mining Company.

The existing Erie Plant has a historic capacity of 100,000 t/d, comprising four-stage crushing and 34 mill lines, each with a rod mill and ball mill. Cliffs operated the plant on behalf of the owners, processing 100,000 t/d of taconite ore. In the mid-1980s the consortium was consolidated into a single owner, LTV Steel.

The plant is in good physical condition and operated at or near full capacity prior to its closure. PolyMet has not operated the plant, but has examined it in detail and believes the mill is serviceable. PolyMet plans to use one of two primary crushers and one-third of its historic capacity (32,000 t/d) to treat the material mined from the NorthMet deposit in Phase I.

We believe management may optimise the potential of the plant in Phase I while staying within the permitted emissions level. [emphasis added]  We believe it could achieve a 20% to 30% increase in throughput while deploying minimal additional capital, which should enhance the project’s economics.

Phase II will further treat the milled nickel concentrate. The concentrate from the flotation cells will be put into a large pressure oxidation vessel called an autoclave. Oxygen will be added to create a chemical reaction with the nickel concentrate. Heat generated by the exothermic reaction and high pressure will drive the metals into solutions. Metals, including nickel, cobalt, platinum, palladium and gold, will be precipitated out of the solution and sold as semi-finished products: nickel-cobalt hydroxide and precious metal precipitate. Limestone will be added to the excess solution to neutralise acidity. This will create synthetic gypsum that will be stored in a lined facility. [Sounds like some serious potential for pollution here....]

The NorthMet resource

The NorthMet copper-nickel-PGM ore body is near a number of shut-down iron ore mines and the operational Peter Mitchell open-pit iron ore mine is approximately one mile north. The NorthMet ore body comprises 275 Mt of proven and probable reserves grading 0.79% copper equivalent with measured and indicated (M&I) mineral resources of 694 Mt grading 0.74% copper equivalent (Exhibit 2). We believe the size and scope of the ore body could support a much larger project, which would create meaningful additional value.  [Now we are getting to why the SDEIS does not capture the real impacts ....]

Potential resource expansion

We believe there is a good chance PolyMet will be able to expand the size of its resource by 50-100% based on what we learned on a site visit. [emphasis added]  The eastern end of the pit is cut off by the property boundary with the Teck-Mesaba project. However, down dip to the south and west the geology is open (Exhibit 3). Also, based on drill work to date there is a chance PolyMet will be able to identify economic mineralisation on the hanging wall and at depth. Expansion to 90,000 t/d Phase I is designed to operate at 32,000 t/d, which uses 32% of the Erie Plant capacity. Based on rule-of-thumb estimates, the capital cost of expanding to 90,000 t/d would be approximately US$400m. Expansion would require additional environmental review and permitting. We have assumed it would take two years to secure permits and one year to expand the mine to 90,000 t/d and update the mill. It operated at 100,000 t/d previously, so a 90,000t/d rate would leave a 10% cushion; the NorthMet deposit is large enough to support the larger capacity. We assume PolyMet would restructure its debt to fund the capital for the project and that it would begin working on permitting the expansion project within six months of receiving its permits for Phase I. On this basis it could complete its expansion by Q218. Third-party processing There are roughly 11 mineral properties within shipping distance of PolyMet’s mill.

We believe there is a good chance PolyMet will decide to toll process third-party ore or form some relationships with one or more the local projects. We believe government permitting agencies may encourage the developers of other mining properties in the area to work out an arrangement with PolyMet to use its pre-existing mill and tailings pond. This would limit the footprint of mining and processing in the area.

Like the expansion case, we believe it would take two years to permit the expansion of the mill and one year to complete the mill modernisation. But since we do not know the grade of the ore to be toll processed or its metal composition we cannot model the potential contribution a third party relationship may have. We believe eventually the copper-nickel-PMG properties in the Duluth Complex that are close to the Erie plant facility may consolidate under PolyMet.

Potential future permitting of throughput expansion up to 90,000 t/d

We assume PolyMet would begin working on permitting the expansion to 90,000 t/d within six months of receiving its permits for Phase I, permitting would take two years and construction would take one year. On this basis, it could complete its expansion by May 2018.

Ok, this is a bit long and tedious, but suggests that the scenarios laid out in the SDEIS are low-balls, not representing what will really happen in the genie is let of out the bottle.  Plainly, much more comprehensive studies are needed.
How much is this mine “needed?”  One of purposes of environmental review under both federal and Minnesota statutes is supposed to be consideration of alternative to the proposed project.  In practice this is rarely done in any meaningful way, and it has not been done in this matter.  But Paula Maccabbee of WaterLegacy has produced “RECYCLING OF NON-FERROUS METALS–AN ALTERNATIVE TO SULFIDE MINING IN MINNESOTA.” Take a look.
According to the DNR,  Comments will be accepted until 4:30 PM CT on Thursday, March 13, 2014.  NorthMetSDEIS.dnr@state.mn.us
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Martin King’s birthday

In  the 1980’s I was working as a consultant to the engineering department of a large chemical company.  Like many US corporations around that time, they had looked at the the changing demographics of the US population and figured out that their future workforce couldn’t be all white and all male.  White people were going to be a decreasing proportion of the population. and their just wouldn’t be enough of them.   So they needed to change their corporate culture enough that black and brown and yellow and female people would find it acceptable.  This, in corporate-speak, was called something like “celebrating diversity.”

In practice this meant hiring consultants to put on “diversity” programs and meetings.  The majority of people working there probably understood the point, and were supportive or at least accepting.  But some were not, and this is hardly surprising.  After all, the culture was not only “white,” but Southern, “conservative,” Republican, and upper-middle-class.  Many had grown up, as did I, seeing “Martin Luther King is a COMMUNIST” billboards.  Having been taught all their lives to dislike, if not to hate, King and what he stood for, it’s not surprising they felt betrayed by their managers’ change of tune.

What was the fundamental beef with King?  That he was uppity.  That he asked for too much.  That he was unreasonable.  That he wouldn’t take “no” for an answer.  Above all, that he was do damn charismatic and effective.

At my client’s offices, I had this to say:  Honoring the trouble maker King, 20 years safely dead, doesn’t take a lot of courage.  Deceased troublemakers mellow with time.  The real test of our sincerity in supporting the righting of   injustice is how we are treating the troublemakers who are active NOW.  Who are the annoying Black leaders active at the moment and how can we support THEM?

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Minnesota’s “Legislative Energy Commission” vs public participation

The Minnesota Legislature has a “Legislative Energy Commission” (LEC) made up of Senators and Representatives. The law establishing it says:  “The commission shall continuously evaluate the energy policies of this state and the degree to which they promote an environmentally and economically sustainable energy future.” Continue Reading →

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Minnesota agency comments on EPA Region 5 climate change draft report…..??

The US Environmental Protection has laid out a  Draft Region 5 Climate Change Adaptation Implementation Plan (draft dated September 18, 2013)  and is accepting public comments through January 3, 2014.

For whatever reason, I just found about this yesterday.  Apparently, no effort has been made to alert the public, although NOTHING is more important to our future than climate change.  (Of course, we are having a cold winter, but that’s weather, not climate.)

The Minnesota Pollution Control Agency has been preparing comments.

I lack confidence in the PCA’s management to address this issue, mainly because of a disgraceful rulemaking in 2012, in which the breakpoint for regulating carbon dioxide was raised from 100 tons to 100 thousand tons.  More on that here.  More also from Carol Overland at Legalectric.org  Lots of people objected, but it seemed to be one of those “done deal” situations.  The Administrative Law Judge, Miguel Cervantes, seemed to be hearing the arguments, but–suspiciously, in my view–the order upholding the PCA’s indefensible position was signed by a different ALJ, Eric Lipman.  Neither the PCA or the Office of Administrative Hearings covered itself with glory….

Some rumors have circulated that MPCA staffers developed stronger, more substantial comments than the PCA’s management plans to submit.  There would be nothing surprising or unusual about this if true.  The PCA is a politically controlled bureaucracy and most politicians respond primarily to the short-term agendas of industrial interests.  Certainly Governor Dayton seems to.

But consider:  We are at a critical point in history and how we react, or if we react in advance, to climate change will have a big impact on our children and their children….  The only way to get real “value” from environmental regulatory staffers is to have technically and ethically competent, motived people and let them do real work, protected as much as possible from censorship and retribution.

With this in mind I sent in the following information requestto the head of the MPCA, and similar requests to MDH and DNR.

Dear Commissioner Stine:

It is my understanding that EPA Region 5 is accepting public comments on the Draft Region 5 Climate Change Adaptation Implementation Plan (draft dated September 18, 2013) through January 3, 2014.  It is also my understanding that the MPCA and perhaps other Minnesota agencies have been working on comments.

Pursuant to the MN Data Practices Act, I request copies of all comments and related correspondence, including all versions of all drafts of comments/proposed comments.

If this request raises any questions please contact me.

Yours very truly,

Alan Muller

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Passing of Mandela

The passing of Nelson Rolihlahla Mandela reminds us of the difference one inspired individual can make. And the courage and determination needed. Mandela was imprisoned for “conspiracy to overthrow the government” for 27 years and reportedly was on a US “terrorist” watch list until 2008.

This is from Bobby Peek, a leading South African environmental justice campaigner: Continue Reading →

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NRC Nuclear nonsense hearing in Minnetonka December 4th

Nuclear Regulatory Commission “Waste Confidence” public meeting December 4.

Minnetonka, Minnesota
Minneapolis Marriott Southwest
5801 Opus Parkway
Minnetonka, MN 55343

Open House
6:00-7:00 p.m. CST
Meeting
7:00-10:00 p.m. CST

This meeting (apparently it is not a formal public hearing) was originally scheduled for October 17th but postponed due to the federal government “shutdown.”  Previous meetings have had a three-minute time limit for speakers.  “NRC staff will not be available to answer questions related to the proposed rule or DGEIS during the formal meeting.”   (But they will at the Open House.) Continue Reading →

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